Bodah Charges

FILED: JEFFERSON COUNTY CLERK 10/08/2019 04:27 PM INDEX NO.
EF2019-00002245
NYSCEF DOC. NO. 1 RECEIVED NYSCEF: 10/08/2019
STATE OF NEW YORK

SUPREME COURT COUNTY OF JEFFERSON
THE PEOPLE OF THE STATE OF NEW YORK, by

LETITIA JAMES, Attorney General of the State of New
York, VERIFIED PETITION
Petitioners,
-against-
KENNETH G. BODAH, JR., BETH ANN BODAH and

TRAVIS J. BODAH,
_____________________________Respondents._______
The People of the State of New York, by their attorney, Letitia James, Attorney General
of the State of New York, allege as follows:
PRELIMINARY STATEMENT
1. Petitioner brings this special proceeding pursuant to Executive Law § 175 against
the respondents for multiple violations of article 7-A of the Executive Law in their solicitation,
collection, maintenance, and distribution of funds raised from the community for the benefit of
H.B.,1 a minor child who survived a tragic fire in the City of Watertown. Specifically, the
respondents have, inter alia, failed to turn over funds raised to the beneficiary within 60-days,
failed to register as a charitable organization with the Attorney General, fraudulently spent funds
raised in ways inconsistent with the public solicitations and fundraisers, and made false
statements to the Attorney General’s Office regarding the fundraising accounts, and failed to turn
1 For purposes of protecting the identity of a minor child, her initials are utilized herein.
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FILED: JEFFERSON COUNTY CLERK 10/08/2019 04:27 PM INDEX NO. EF2019-00002245
over records related to the accounts, concealing over $70,000.00 of over $100,000 in raised
funds.
2. This special proceeding seeks restitution and damages by compelling
Respondents to turn over all money raised—without any deduction whatsoever—for the benefit
of H.B. to her (care of her mother and natural guardian), and also for penalties and costs as
authorized by Executive Law §§ 175(2) and 177(2)(b). As demonstrated herein, and in the
attorney affirmation and memorandum of law, the State has demonstrated the potential for
irreparable harm, and a likelihood of success on the merits of this application.
3. As summarized below and described in more detail in the accompanying attorney
affirmation, well more than 60-days after almost all funds at issue were raised, no money had
been turned over to the primary beneficiary. Additionally, Respondents Kenneth G. Bodah, Jr.
and Beth Ann Bodah—through prior counsel—made false representations to the NYAG
regarding the amount of money raised, and thereafter began secretly spending moneys they had
concealed on home appliances, furniture, and other home contracting supplies.
PARTIES AND JURISDICTION
4. Petitioner is the People of the State of New York, by their attorney, Letitia James,
Attorney General of the State of New York.
5. Respondents Kenneth G. Bodah, Jr. and Beth Ann Bodah are married and reside
at 220 Elm Street in the City of Watertown, County of Jefferson.
6. Travis J. Bodah is the brother of Kenneth G. Bodah, Jr., and resides at 18014
Sandy Lane in the Village of Adams Center, County of Jefferson.
7. Upon information and belief, all respondents are adults not subject to any
disability or guardianship.
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8. Respondents conducted public solicitations to benefit a minor child in the wake of
a community tragedy. Currently, Kenneth and Travis Bodah are signatories on an account
housing said funds at Watertown Savings Bank, 111 Clinton Street, Watertown, NY 13601.
9. The Supreme Court has jurisdiction over proceedings brought by the Attorney
General pursuant to Executive Law § 175, and venue is proper in Jefferson County as it is the
county of residence of all three respondents and the county where the underlying conduct
occurred.
FACTS
10. On February 14, 2019, a tragic fire took the lives of Aaron Bodah and four of his
five minor daughters. One minor daughter, H.B., survived, having been directed by her father to
run to seek help. Mr. Aaron Bodah’s brother, respondent Travis Bodah, was also a resident of the
home, but was at work during the course of the fire. The mother and co-parent of all five girls,
Melissa Davey, resided separately.
11. The magnitude of the tragedy shook the community and unleashed multiple
fundraising efforts for the benefit of the young surviving daughter, including a GoFundMe
campaign, community fundraisers, and a fundraising effort by members of Kenneth Bodah’s
union. The fundraising solicitations referenced that the moneys were being raised for H.B., the
surviving daughter.
12. One of the largest solicitations was through a GoFundMe page organized by
Meghan Manisero “on behalf of Kenneth Bodah.” It stated, “[d]ue to an overwhelming number
of requests, we have elected to create this page in an effort to collect donations for 13 year old
[H.B.] ... It is an absolute miracle [H.B] is alive and well as we continue to shower her with
love and blessings during this difficult time. Thank you so much for your thoughts, prayers, and
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ongoing support.” The GoFundMe closed by stating, “Hey everyone! I am Meghan Manisero,
(future) daughter-in-law of Ken and Beth Bodah of Watertown, NY. I would like to take this
opportunity to thank everyone who graciously donated to support [H.B.] after tragedy struck her
family in February. I will be closing this campaign and all future donations can be directed to
Ken and Beth as they have set up an account at Watertown Savings Bank in [H.B.J’s name. All
funds raised through this campaign will be directed to that account at Watertown Savings Bank
to assure all moneys raised go to [H.B.] Thank you again for all of your generosity and support
through this difficult time.”
13. On February 19,2019, the Watertown Daily Times wrote about a prayer vigil at
the scene of the fire, recognizing H.B. as the survivor of the devastating fire and stating that a
“Bodah Family Memorial Fund has been set up to benefit the survivors, care of Watertown
Savings Bank, 111 Clinton Street.”
14. Additional public solicitations were announced in the Watertown Daily Times on
February 20, 2019, with t-shirt sales. According to the article, “[a] 11 the money from the T-shirts
will go toward the daughter, [H.B], 13, who survived last Thursday’s devastating fire that took
the lives of her father, Aaron, 38, and her four sisters.” The article also referenced that two local
McDonald’s restaurants would host a fundraiser “for [H.B.] and Melissa Davey, the mother of all
five of the Bodah children.” One dollar from each Shamrock Shake would be placed in the
Bodah Family Memorial Fund and the Melissa Davey and [H.B.] Fund, c/o the Watertown
Savings Bank, 111 Clinton Street, Watertown, NY.”
15. Additional fundraising was conducted by Kenneth Bodah’s former union, raising
money “to help out for funeral, medical and other costs associated with it,” and also noting that
“There is one sole survivor, Ken’s niece [H.B.] who is 13 years old. A savings account has been
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established at Community Savings Bank. Donations can be made at any Community Savings
Bank or mailed to: For the Benefit of [H.B.].”
16. Multiple businesses and community leaders similarly used social media to
advertise fundraisers for H.B., utilizing language such as “Hope for [H.B.],” “Help the Bodah
Family,” “100% of the donations will be directly given to the family” and “hosting a benefit for
[H.B.] and her family.”
17. On February 23, 2019, Kenneth and Beth Bodah published a letter to the
Watertown Daily Times thanking the community for the outpouring of support. In the letter, they
note, “We thank everyone for their financial support for [H.B.]. We promise that all funds
entrusted to us will be used solely for [H.B.]’s benefit. In the next week we will begin
investigating options, such as an irrevocable trust and a 529 Plan, to help secure [H.B.]’s future.
Also, we will use these tools as a promise that we will protect and responsibly manage these
funds solely for [H.B].” Neither Kenneth Bodah, Jr., nor Beth Bodah asked for or received
written permission to fundraise on behalf of H.B.
18. As of August 2, 2019, neither Kenneth nor Beth Bodah had turned over any of the
fundraised moneys to [H.B.] or her mother and natural guardian, Melissa Davey. On that date,
the Attorney General made due demand to Kenneth Bodah and Beth Bodah to comply with
Executive Law § 172-a, and to provide an accounting or detailed summary of all moneys raised
in calendar year 2019, the current location of such funds, and to the extent the funds were raised
more than 60-days prior to the date of the letter, a plan to turn over the funds without deduction,
as required by the statute.
19. The Bodahs responded on August 26, 2019 by and through their then-attorney,
David Renzi, Esq. The response included what was asserted to be a summary of all fundraising
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efforts: documentation for the Community Savings Bank account which held the NYSCOPBA
funds and their use for a memorial bench and a church contribution; a list of the GoFundMe
contributions; and documentation showing that the remaining funds had been placed in a 529
College Savings Program owned by Kenneth Bodah and listing H.B. as the beneficiary. No
documents were produced for the Bodah Family Memorial Fund held at Watertown Savings
Bank.
20. By response dated August 26, 2019, the Attorney General pointed out that the
fundraising solicitations had not stated they were for the future education of H.B., nor had it been
for a memorial bench2 or church donations. The NYAG further noted that the statute specifies
that no reductions may be made to the fundraised moneys. On September 3, 2019, the Bodahs’
then-attorney responded that they would comply with turning the moneys over to H.B.’s mother
and natural guardian.
21. On September 6, 2019, the undersigned detailed that the funds, to wit, $9,361.61
from the Community Bank NA Funds, $25,6803 from the GoFundMe donations, and “[a]ny
additional donations collected for [H.B.]” were expected to be turned over to H.B. The letter also
stated, “Please also provide my office with a sworn, notarized statement that said funds represent
all moneys collected, without reduction, on behalf of [H.B.] as of the date of the statement.”
22. On September 20, 2019, Attorney Renzi hand delivered a cashier’s check made
payable to H.B. in the amount of $35,021.61. Mr. Renzi’s accompanying letter stated that he
would “now consider [his] file closed.” No statement from the Bodahs was included.
2 Note that none of H.B.’s sisters are interred at the cemetery, although a small portion of their cremains were
interred with their father in his casket, with the consent of Ms. Davey, their mother. Further, Ms. Davey’s then-
employer graciously had agreed to pay all funeral and interment expenses, which was declined in part by the
respondents. Subsequently, fundraised moneys were used on the sole initiative of the respondents, Kenneth and Beth
Bodah, for a memorial bench and an unknown number of cemetery plots.
3 The letter stated the GoFundMe amount was $25,660, a typographical error.
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23. On September 24, 2019, the Attorney General’s Office obtained documentation
from the Watertown Savings Bank for “The Bodah Family Memorial Fund” account, held in the
names of Respondents Kenneth and Travis Bodah. Between February 19, 2019 and September
23, 2019, a total of $97,199.29 was deposited. The following deductions had been made from the
account:
a. 7/23/2019 $812.64 Check to St. Patrick’s Church, notation cemetery
b. 9/3/2019 $586.03 Debit Card payment to Lowe’s
c. 9/4/2019 $1,495.79 Debit card payment to Lowe’s
d. 9/11/2019 $1,068.23 Debit card payment to Lowe’s
e. 9/12/2019 $453.86 Debit card payment to Wayfair.com
f. 9/16/2019 $35,021.61 Withdrawal by Travis Bodah for check to H.B.
g- 9/16/2019 $683.63 Debit card payment to Lowe’s
h. 9/19/2019 $1,529.65 Debit card payment to Lowe’s
24. Further investigation revealed that the expenditures at Lowe’s, which total
$5,363.33, were for, inter alia, a stainless steel sink with faucet, garbage disposal, an under sink
garbage can assembly, an electric range, microwave, dishwasher, laundry stacking kit, side-by-
side stainless steel refrigerator with ice maker, dehumidifier, an end table, shower faucet and
handle, and a stackable washing machine and gas dryer with a protection plan, and other home
contracting supplies.
25. Wayfair.com is a self-described seller of “home furnishings, decor, home
improvement, housewares, and more.”
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26. On September 24, 2019, the Attorney General’s Office also obtained
documentation from Community Bank NA that $9,361.61 had been deposited in an account
titled to “Kenneth G. Bodah Jr. Cust. UTMA [H.B.].” That fund had been reduced as follows:
a. 6/28/2019 $8,375.00 Withdrawn by Kenneth Bodah for A. Cozzi & Co.
b. 9/6/2019 $987.36 Withdrawn by Kenneth Bodah for St.

Patrick’s Church
27. Between the two accounts created for H.B.’s benefit and controlled by the
respondents, a total of $106,560.90 were deposited. To date, only $35,021.61—or 32.87%-of
the funds raised have been turned over to H.B. or her mother and guardian.
CAUSES OF ACTION
FIRST CAUSE OF ACTION AGAINST ALL RESPONDENTS

PURSUANT TO EXECUTIVE LAW § 175
VIOLATION OF EXECUTIVE LAW § 172-a:
FAILURE TO PAY FUNDS TO BENEFICIARY
28. Petitioner realleges paragraphs 1-27 as though fully set forth herein.
29. Executive Law § 175(2) authorizes the Attorney General to “bring an action or
special proceeding in the supreme court, in the name and in behalf of the people of the state of
New York, against a charitable organization and any other persons acting for it or in its behalf
[...] for an order awarding restitution and damages, penalties and costs; [...] whenever the
attorney general shall have reason to believe that the charitable organization or other person: (a)
is violating or has violated any provisions of this article.”
30. Article 7-A of the Executive Law sets forth the registration and reporting
requirements of charitable organizations who solicit and/or maintain charitable funds within the
State. A “charitable organization” is defined in § 171-a as “[a]ny benevolent, philanthropic,
patriotic, or eleemosynary person or one purporting to be such...” (emphasis supplied).
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31. Section 172-a(2)(c) states that the requirements of the article do not apply to:
[pjersons requesting any contributions for the relief of any

individual, specified by name at the time of the solicitation, if all of
the contributions collected, without any deductions whatsoever, are
paid to or for the benefit of the named beneficiary. [...] In the event
that money collected for the relief of any individual, without any
deductions whatsoever, is paid to or for the benefit of the primary
beneficiary within sixty days of its receipt, then all requirements of
this paragraph shall be deemed to have been complied with.
32. Respondents have solicited, collected, and maintained control of funds which
were solicited for the relief of H.B. following her family’s tragedy, yet they have failed to turn
those funds over to the beneficiary. Even more egregiously, they have concealed more than two-
thirds of the funds from the Attorney General in her efforts to ensure compliance with the statute,
and spent over $15,000 of the money raised in ways that were not “for the benefit of’ H.B.
33. The respondents have violated Executive Law § 172-a by failing to promptly turn
over, “without any deductions whatsoever,” the funds raised to the intended, named beneficiary
within 60-days, and have spent over $15,000 of said money.
34. Pursuant to Executive Law § 175, the respondents should be compelled to provide
restitution and damages to H.B. by immediately turning over the remaining $71,539.29 raised
and held by the respondents.
35. Further, pursuant to §§ 175 and 177, the respondents should be liable for penalties
of $1,000 per violation of this section, to include but not be limited to: each deduction from
funds raised; failing to turn over the funds within 60-days; and failing to turn over the total
amount held upon demand by the Attorney General.
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SECOND CAUSE OF ACTION AGAINST ALL RESPONDENTS

VIOLATION OF EXECUTIVE LAW § 172: FAILURE TO REGISTER
37. Executive Law § 172 requires that all charitable organizations who solicit
contributions within the State, except those properly exempted by § 172-a, must register with the
Attorney General.
38. Because the respondents have not complied with the provisions of § 172-a, they
are not exempt from the requirements of article 7-A.
39. The respondents have not registered with the Attorney General and are therefore
in violation of § 172.
40. Respondents should be made to comply with the registration requirements of
article 7-A, and, pursuant to Executive Law § 175, the respondents should be compelled to
provide restitution and damages to H.B. by immediately turning over the remaining $71,539.29
raised and held by the respondents.
41. The respondents should further be liable for $1,000 in penalties, pursuant to
Executive Law §§175 and 177 for violating this statute.
THIRD CAUSE OF ACTION AGAINST KENNETH AND BETH BODAH

VIOLATION OF EXECUTIVE LAW § 172-d(l): FALSE STATEMENTS
43. Executive Law § 172-d(l) prohibits making “any material statement which is
untrue in an application for registration, registration statement, a claim of exemption, financial
report, or any other forms or documents required to be filed or filed pursuant to this article...”
44. On August 2, 2019, the Attorney General made a written demand to Kenneth and
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Beth Bodah for an accounting and documents to determine compliance with the exemption in §
172-A(2). Respondents Kenneth and Beth Bodah, by and through their attorney, made false
representations by omission in three written correspondences to the Attorney General, in
violation of the Executive Law.
46. For these violations, the respondents Kenneth and Beth Bodah should each be
liable for a penalty of $1,000 for each false statement, pursuant to Executive Law §§175 and
177.
FOURTH CAUSE OF ACTION AGAINST KENNETH BODAH

VIOLATION OF EXECUTIVE LAW § 172-d(2): FRAUD
48. Executive Law § 172-d(2) prohibits
any fraudulent or illegal act, device, scheme, artifice to defraud or

for obtaining money or property by means of a false pretense,
representation or promise, transaction or enterprise in connection
with any solicitation or with the registration, reporting and
disclosure provisions of this article. The term “fraud” or
“fraudulent” as used herein shall include those acts which may be
characterized as misleading or deceptive including but not limited
to those acts covered by the term “fraud” or “fraudulent” under
subdivision twelve of section sixty-three of this chapter.
49. Kenneth G. Bodah, Jr., has engaged in fraud pursuant to this article by soliciting
funds from the community for H.B.’s “sole” benefit, failing to turn over those funds to H.B.,
misrepresenting to the Attorney General the total amount of funds solicited and donated for
H.B.’s benefit, and spending the money on things that were not for H.B.’s benefit, including
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home appliances and other home contracting supplies.
51. For this fraudulent conduct, Kenneth G. Bodah, Jr. should be liable for penalties
of $1,000 per fraudulent act, pursuant to Executive Law §§175 and 177.
FIFTH CAUSE OF ACTION AGAINST ALL RESPONDENTS

VIOLATION OF EXECUTIVE LAW § 172-d(4): FAILURE TO APPLY
CONTRIBUTIONS IN A MANNER CONSISTENT WITH SOLICITATIONS
53. Executive Law § 172-d(4) prohibits persons from failing “to apply contributions
in a manner substantially consistent with the solicitation [...] or the purposes expressed therein.”
54. Here, the respondents solicited money from the community for H.B.’s benefit,
and all contributions have not been applied in such a manner. Rather, at least nine (9)
expenditures have been made that are inconsistent with the solicitations.
56. For these violations, pursuant to Executive Law §§175 and 177, the respondents
should be liable for a penalty of $1,000 per expenditure in violation of this statute.
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SIXTH CAUSE OF ACTION AGAINST KENNETH AND BETH BODAH

VIOLATION OF EXECUTIVE LAW § 172-d(13):
FAILURE TO PRODUCE BOOKS TO ATTORNEY GENERAL UPON REQUEST
57. Petitioner realleges paragraphs 1 -56 as though fully set forth herein.
58. Executive Law § 172-d(13) prohibits the failure “to produce to the attorney
general any such [financial] books and records within fifteen days of receiving, by certified mail,
a request for such books or records.”
59. Here, the Attorney General sent Kenneth and Beth Bodah, by certified mail, a
letter on August 2, 2019 demanding documents related to the funds raised for H.B.’s benefit. No
records were produced until August 26, 2019, on which partial records—represented as
complete records—were provided to the Attorney General through their attorney. At no point
have Kenneth or Beth Bodah produced books or records related to the entirety of the funds raised
and held in the Watertown Savings Bank account, in violation of this statute.
61. For Kenneth and Beth Bodah’s failure to produce the books and records
demanded by the Attorney General, pursuant to Executive Law §§175 and 177, they should be
liable for a penalty of $1,000 each.
SEVENTH CAUSE OF ACTION AGAINST KENNETH AND BETH BODAH

VIOLATION OF EXECUTIVE LAW § 174-d:
USE OF THE NAME OF ANOTHER FOR SOLICITATION WITHOUT CONSENT
63. Executive Law § 174-d(l) states that “[n]o person shall, for the purpose of
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soliciting contributions from persons in this state, use the name of any other person [...] without
the written consent of such other person.”
64. Here, the respondents solicited money from the community using H.B.’s name,
without written consent of her or her mother.
66. For these violations, pursuant to Executive Law §§ 175 and 177, Kenneth and
Beth Bodah should be liable for a penalty of $1,000 per violation of this statute.
WHEREFORE, the petitioner respectfully requests the Court grant relief pursuant to
Executive Law §§175 and 177 by issuing an order as follows:
a. Ordering Respondents to comply with the registration and filing requirements of

Executive Law § 172;
b. Ordering Respondents to make a full accounting of all funds raised, between

February 14, 2019 to the present, on behalf of H.B., The Bodah Family Fund, The
Bodah Family Memorial Fund, H.B. Fund, Melissa Davey, Kenneth Bodah, Beth
Bodah or any other named beneficiaries stemming from the tragic fire on
February 14, 2019. Such accounting shall include the location and account
numbers of all said funds, as well as all documentation and activities related to
those bank accounts, and any solicitations associated with those accounts;
c. Directing Respondents to transfer the entirety of the funds identified in this

petition and the accompanying affirmation and exhibits, in the amount of at least
$71,539.29, to H.B. (c/o her mother, Melissa Davey) as the intended beneficiary
of the funds per the solicitations and as required by Executive Law § 172-a;
d. Pursuant to Executive Law §§ 175(2) and 177(2)(b), assessing penalties of $1,000

per Respondent, per violation of the article in accordance with Executive Law
article 7-A, and as outlined above, together with costs in an amount to be
determined by the Court; and
e. For such other and further relief as the Court deems just and proper.
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Dated: October 8, 2019

Watertown, New York LETITIA JANIES
New York State-Attorney General
State Office Building, 10th FI.

ashington Street
Watertown, New York 13601
315-523-6080
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VERIFICATION
DEANNA R. NELSON, an attorney admitted to practice before the courts of this State,
affirms pursuant to CPLR 2106 that:
1. She is an Assistant Attorney General of the State of New York, In Charge of the
Watertown Regional Office, and has read the foregoing Verified Petition and knows the
contents thereof; that the same is true to deponent's knowledge, except as to the matters stated
therein to be alleged on information and belief, and that as to those matters, deponent believes
them to be true.
2. The sources of deponent's information and the grounds of her belief of the
allegations contained in the Verified Petition are derived from deponent's investigation of the
facts of this proceeding and an examination of the file herein.
3. Deponent certifies that, to the best of her knowledge, information and belief,
formed after reasonable inquiry under the circumstances, the presentation of this document, or
the contentions contained therein, are not frivolous as defined in Part 130-1.1 of the Rules of the
Chief Administrator.
Dated October 8, 2019

Watertown, New York
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FILED: JEFFERSON COUNTY CLERK 10/08/2019 04:27 PM INDEX NO.

STATE OF NEW YORK

THE PEOPLE OF THE STATE OF NEW YORK, by

KENNETH G. BODAH, JR., BETH ANN BODAH and

of the State of New York, allege as follows:

2. This special proceeding seeks restitution and damages by compelling

irreparable harm, and a likelihood of success on the merits of this application.

3. As summarized below and described in more detail in the accompanying attorney

concealed on home appliances, furniture, and other home contracting supplies.

PARTIES AND JURISDICTION

Attorney General of the State of New York.

at 220 Elm Street in the City of Watertown, County of Jefferson.

Sandy Lane in the Village of Adams Center, County of Jefferson.

8. Respondents conducted public solicitations to benefit a minor child in the wake of

Melissa Davey, resided separately.

campaign, community fundraisers, and a fundraising effort by members of Kenneth Bodah’s

through this difficult time.”

Savings Bank, 111 Clinton Street.”

Savings Bank, 111 Clinton Street, Watertown, NY.”

Bank or mailed to: For the Benefit of [H.B.].”

[H.B.] and her family.”

written permission to fundraise on behalf of H.B.

as required by the statute.

and natural guardian.

a. 7/23/2019 $812.64 Check to St. Patrick’s Church, notation cemetery

b. 9/3/2019 $586.03 Debit Card payment to Lowe’s

c. 9/4/2019 $1,495.79 Debit card payment to Lowe’s

d. 9/11/2019 $1,068.23 Debit card payment to Lowe’s

e. 9/12/2019 $453.86 Debit card payment to Wayfair.com

f. 9/16/2019 $35,021.61 Withdrawal by Travis Bodah for check to H.B.

g- 9/16/2019 $683.63 Debit card payment to Lowe’s

h. 9/19/2019 $1,529.65 Debit card payment to Lowe’s

25. Wayfair.com is a self-described seller of “home furnishings, decor, home

improvement, housewares, and more.”

a. 6/28/2019 $8,375.00 Withdrawn by Kenneth Bodah for A. Cozzi & Co.

b. 9/6/2019 $987.36 Withdrawn by Kenneth Bodah for St.

respondents, a total of $106,560.90 were deposited. To date, only $35,021.61—or 32.87%-of

FIRST CAUSE OF ACTION AGAINST ALL RESPONDENTS

is violating or has violated any provisions of this article.”

State. A “charitable organization” is defined in § 171-a as “[a]ny benevolent, philanthropic,

patriotic, or eleemosynary person or one purporting to be such...” (emphasis supplied).

[pjersons requesting any contributions for the relief of any

within 60-days, and have spent over $15,000 of said money.

and held by the respondents.

amount held upon demand by the Attorney General.

SECOND CAUSE OF ACTION AGAINST ALL RESPONDENTS

are not exempt from the requirements of article 7-A.

40. Respondents should be made to comply with the registration requirements of

raised and held by the respondents.

Executive Law §§175 and 177 for violating this statute.

THIRD CAUSE OF ACTION AGAINST KENNETH AND BETH BODAH

untrue in an application for registration, registration statement, a claim of exemption, financial

representations by omission in three written correspondences to the Attorney General, in

violation of the Executive Law.

and held by the respondents.

FOURTH CAUSE OF ACTION AGAINST KENNETH BODAH

48. Executive Law § 172-d(2) prohibits

any fraudulent or illegal act, device, scheme, artifice to defraud or

home appliances and other home contracting supplies.

and held by the respondents.

FIFTH CAUSE OF ACTION AGAINST ALL RESPONDENTS

and held by the respondents.

SIXTH CAUSE OF ACTION AGAINST KENNETH AND BETH BODAH

a request for such books or records.”